Carolyn Jean Brown, Petitioner v. McLennan County Children's Protective Services, Respondent

Summary

The Texas Supreme Court affirmed the trial court’s decree terminating Carolyn Jean Brown’s parental rights, holding that her executed affidavit of relinquishment and waiver of citation was valid under the Family Code and did not violate due process. The Court found no error on the face of the record regarding lack of citation, absence of a formal statement of facts, or denial of counsel. A dissent argued the pre‑suit waiver was unconstitutional and should be struck down.